CHAPTER 9: Serving Taxpayers with Disabilities

Section 504 of the Rehabilitation Act requires that people with disabilities have equal access to tax preparation services provided through the VITA/TCE program. To help ensure equal access, you should evaluate the availability of resources and consider the type of reasonable accommodations that taxpayers with a disability may request. It is important to recognize that not all people with similar disabilities require the same accommodations, and sometimes, you must be flexible and creative. As with the tax preparation process, allow your interview to guide you through the process of giving the help needed. If there are any questions about whether to approve or deny a request for an accommodation, you can consult with the IRS Civil Rights Unit at civil.rights.division@irs.gov .

Reasonable and effective alternative accommodations that allow equal access is a requirement for taxpayers with a disability. If you deny a request for an accommodation and the taxpayer challenges the denial, you must be able to show that granting the accommodation would cause an undue hardship or fundamental alteration to your program.

Additional References:

• Publication 5192, Ten Key Points for Communicating with People with Disabilities

• Publication 5231, Key Points for Communicating with People who are Deaf and Hard of Hearing

• Site Coordinator Corner, Fact Sheets and Civil Rights Unit Advisories

Serving Taxpayers with Mobility Impairments

To prepare your site for the upcoming season, make sure that you and your volunteers are familiar with physical barriers that would prevent taxpayers with limited mobility from being able to navigate the site. Take proactive measures to address the following barriers:

• Are there steps leading into the building that would prevent wheelchair access? If so, is there an alternate entrance at street level or a ramp available for wheelchair access? If an alternate entrance is available, are there signs at the main entrance informing taxpayers of the accessible entrance?

• Are doorways wide enough to accommodate a person in a wheelchair?

• If the site provides restrooms, are they accessible for people with disabilities?

• Is there enough space around a tax preparation station to allow for wheelchair access?

• Are there tax preparation stations on the ground floor of the building, or is there elevator access to other floors?

Serving Taxpayers Who Are Blind or Have Low Vision

Taxpayers who are blind or who have low vision may face unique challenges when completing Form 13614-C:

• For taxpayers who can read printed materials, enlarging a copy of Form 13614-C, Intake Interview and Intake/Interview and Quality Review Sheet, may be the only accommodation necessary.

• For taxpayers who cannot read print, offer to have a volunteer greeter or preparer read Form 13614-C to the taxpayer and record their answers.

• If the taxpayer has called ahead for an appointment, schedulers may offer to send the taxpayer a link to Form 13614-C within an email. Many taxpayers who are blind or low vision have access to special technology that will allow them to complete the form on their own computers.

  • When reviewing a tax return with a taxpayer who is blind, the reviewer should be prepared to verbally read the key information to the taxpayer, rather than pointing to the information. Consider finding a private space to read this information aloud. Taxpayers can usually offer suggestions about the best way you can help them.

Serving Taxpayers Who Are Deaf or Hard of Hearing

Taxpayers who are deaf or hard of hearing have varying ranges of language skills and abilities. Some can communicate verbally with you, while others cannot. Some can read lips, and some communicate with

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English Exact Sign which is a method of sign language that mimics the English language precisely as spoken. However, most taxpayers who are deaf or hard of hearing communicate with American Sign Language (ASL). Consider the following items when working with taxpayers who are either deaf or hard of hearing:

• Be aware ASL is different from spoken English as both languages differ in vocabulary and grammar. Therefore, do not assume that simply writing notes between yourself and the taxpayer is an acceptable means of communicating important and specific information needed to prepare a complete and accurate tax return. Writing notes, however, can be helpful for basic interactions such as obtaining taxpayer contact information and arranging for the provision of a sign language interpreter.

• Have a certified or licensed ASL interpreter (requirements may vary from state to state) available to aid taxpayers who request such an accommodation. Find organizations in or near your community that may be able to help supply interpreter services.

• Allow time to coordinate schedules with both the taxpayer and the interpreter. You may not be able to immediately obtain interpreter services.

• Allow more time when preparing returns for someone who requires an interpreter. The communication of information through a third party often means preparation time will be longer than usual.

• Consider offering interpreter services to taxpayers because taxpayers may not want family members or friends to know their personal tax information. Taxpayers may choose to bring someone they trust to interpret for them, but this should not be your first solution. It is their right to expect the same level of privacy and confidentiality any taxpayer would receive through the provision of a qualified interpreter.

• Decide the best place to accommodate the tax preparer, the taxpayer, and the interpreter, comfortably. The taxpayer should always be able to see the interpreter.

• Speak directly to the taxpayer, not to the interpreter. For instance, it is not proper to ask the interpreter, “Can you ask him if he brought a blank check so we can enter his bank information for direct deposit?” Instead, ask the taxpayer, “Did you bring a blank check so we can enter your bank information for direct deposit?” This can be challenging for volunteers who have not worked with an interpreter on behalf of a taxpayer.

  • Supply some degree of visual privacy when preparing returns for taxpayers who are deaf, especially when multiple sign language users are present in the same space. Sign language is visual conversation.

  • Provide a quiet private space to maximize comprehension and minimize confusion when possible. Background noise can be distracting and make it difficult for a taxpayer who is hard of hearing to understand what you say.

  • Avoid covering your mouth or looking away when speaking to taxpayers who are hard of hearing. These taxpayers may be relying, in part, on reading lips to receive the information you are presenting. Turning away from them can affect their ability to do such.

  • Use a consistent volume when speaking to taxpayers who are hard of hearing.

  • Remember, individuals who are deaf or hard of hearing, but are verbal, might not understand you while you are wearing a mask. They may normally lip read to understand. However, we do not recommend removing your mask. You need to ask what communication methods work best for them.

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Helpful Suggestions in Obtaining Interpreters

• Contact the university near you that teaches sign language and ask for a graduate student or an experienced student volunteer. Many schools are looking to partner with organizations so that their senior level students can get credit hours for volunteer work.

• Contact a partner with a local organization whose mission is to establish and maintain a network of services for the deaf, hard-of-hearing, late deafened (hearing loss occurring after childhood), and deafblind.

Partners that receive federal funded grants represent less than 10% of our total partners, so the cost for paying for interpreter services may not be reasonable for a non-grant funded VITA/TCE partner depending on the circumstances. However, some have processes in place, but this may result in rescheduling an appointment with the taxpayer to meet with the interpreter. Even grant funded partners may have to reschedule an appointment for supplying these services because interpreters may not be at the site full time.

All volunteer interpreters must certify in the Volunteer Standards of Conduct. However, there is no requirement to be tax law certified.

American Sign Language Video Resources

SPEC partners with the National Disability Institute and National Association of the Deaf. SPEC identified the need to provide more information regarding free tax preparation services for deaf and hard of hearing taxpayers who use ASL as their primary language. SPEC has created a series of ASL videos describing the return preparation process available at VITA/TCE sites. These videos help volunteers who serve as ASL interpreters and are useful for anyone wanting to become more familiar with the tax preparation process.

The videos are on IRS.gov at American Sign Language (ASL) Videos

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